In a regulatory filing, Coca-Cola Co. said the Internal Revenue Service told the company after a 5-year audit that it owes an additional $3.3 billion plus interest in unpaid taxes from 2007 to 2009.
The soft drink giant plans to contest the discrepancy, which stems from how the company reports income from foreign licenses in overseas markets.
The IRS has been cracking down on what it calls abuse of so-called "transfer pricing," where companies shift profits from high tax countries to low tax countries to cut down on their bills.
The agency says Coke failed to report income from its overseas licenses for manufacturing, distribution, sales, marketing and promotion of its products.
Coke said in the SEC filing that it was following rules outlined in a 1996 agreement.
"The Company firmly believes that the assessments are without merit and plans to pursue all administrative and judicial remedies necessary to resolve this matter," Coke said in the filing document.